mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021138.json

{
  "document_metadata": {
    "page_number": "91",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page91 of 113\ncore, but of a crime 'distinctly different' from the one alleged.\" D'Amelio, 683 F.3d at 419-21). The standard of review is de novo. D'Amelio, at 416.\nIn contrast, \"[a] variance occurs when the charging terms of the indictment are left unaltered, but the evidence at trial proves facts materially different from those alleged in the indictment.\" Id. (quoting United States v. Salmonese, 352 F.3d 608, 621 (2d Cir. 2003)). A defendant alleging variance must show \"substantial prejudice\" to warrant reversal.\nRigas, 490 F.3d at 226.\n1. The \"Core of Criminality\" of Counts Three and Four Was a Scheme to Cause Underaged Girls to Travel to New York with an Intent to Violate New York Law.\nThe \"core of criminality\" of the Mann Act transportation offenses was a scheme to cause underage girls to travel to New York with the intent that they would engage in sexual activity in violation of New York law. The Indictment itself was clear on its face. Count Four, specifically alleged in the \"to wit\" clauses that the charges were based on Jane's travel \"from Florida to New York, New York\" where Maxwell intended for her to engage in sex acts with Epstein \"in violation of New York Penal Law, Section 130.55.\" Ind. ¶ 21 at A129. Count Three alleged that the object of the conspiracy was to cause underage girls to travel across state lines with the intent that they \"engage in sexual activity for which a person can be charged with a criminal offense\"\n76\nDOJ-OGR-00021138",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page91 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "core, but of a crime 'distinctly different' from the one alleged.\" D'Amelio, 683 F.3d at 419-21). The standard of review is de novo. D'Amelio, at 416.\nIn contrast, \"[a] variance occurs when the charging terms of the indictment are left unaltered, but the evidence at trial proves facts materially different from those alleged in the indictment.\" Id. (quoting United States v. Salmonese, 352 F.3d 608, 621 (2d Cir. 2003)). A defendant alleging variance must show \"substantial prejudice\" to warrant reversal.\nRigas, 490 F.3d at 226.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1. The \"Core of Criminality\" of Counts Three and Four Was a Scheme to Cause Underaged Girls to Travel to New York with an Intent to Violate New York Law.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The \"core of criminality\" of the Mann Act transportation offenses was a scheme to cause underage girls to travel to New York with the intent that they would engage in sexual activity in violation of New York law. The Indictment itself was clear on its face. Count Four, specifically alleged in the \"to wit\" clauses that the charges were based on Jane's travel \"from Florida to New York, New York\" where Maxwell intended for her to engage in sex acts with Epstein \"in violation of New York Penal Law, Section 130.55.\" Ind. ¶ 21 at A129. Count Three alleged that the object of the conspiracy was to cause underage girls to travel across state lines with the intent that they \"engage in sexual activity for which a person can be charged with a criminal offense\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "76",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021138",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "D'Amelio",
      "Salmonese",
      "Rigas",
      "Maxwell",
      "Epstein",
      "Jane"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "02/28/2023"
    ],
    "reference_numbers": [
      "22-1426",
      "59",
      "3475902",
      "683 F.3d",
      "352 F.3d",
      "490 F.3d",
      "130.55"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving sex trafficking and conspiracy charges. The text references specific court cases and legal statutes. The document is well-formatted and legible."
}